Letter to EPA on CRT Rule

CLEAN COMPUTERS: Why Computers? Recycling Info. CCC Publications Green Design Flame Retardants Euro Directives US Initiatives Offensive on NGOs E-Waste Pictures SVTC LINKS: High-Tech Impacts Globalization Health Impacts Act Now! Eco-Maps Join our list-serve Publications Links Contact us Sitemap Archive Photo gallery		SVTC HOME > CLEAN COMPUTER CAMPAIGN > ACT NOW > LETTERS TO EPA ACTION ALERT on E-Waste Export Send a letter to the EPA before Aug. 12, 2002 EPA's proposed CRT rule for Hazardous Electronics Waste management falls far short of stated goals and will likely increase e-waste export and dirty recycling and dumping of pollutants in Asian countries. Further, it fails to address improper e-waste disposal by individual consumers. The US EPA has issued a proposed rule streamlining the hazardous waste management regulations for discarded cathode ray tubes (CRTs) - in computers, computer monitors and televisions in an effort to foster re-use, recycling and proper management of these hazardous products by large volume generators. While this may be a laudable goal, the new provisions create huge loopholes because they actually: Fail to close the disposal loophole allowing millions of computers and CRTs from households and small businesses dumped into the nation's landfills and incinerators; Fail to close the export loophole which now allows an estimated 10 million computer units per year to be shipped to Asia for dirty recycling and dumping. This is contrary to EPA agreed principles of environmental justice and is contradictory to international agreements; Fail to address lead contamination from printed circuit boards; Fail to ensure that recycling is done to the highest environmental standard in the USA; Fail to provide right-to-know provisions to local communities regarding the potential and real hazards from e-waste and e-waste disposal and recycling; Public comments on the proposed rule will be accepted by the EPA until August 12, 2002. It is imperative that recyclers, worker health and safety advocates, and waste reduction activists tell the EPA that the proposed rule is seriously flawed. The Computer TakeBack Campaign urges all those concerned about this issue to take a moment and let the EPA know how you feel. Draft comments are provided with this Alert. The Computer TakeBack Campaign is a national network of organizations promoting producer responsibility for computers and consumer electronics. For more information contact: David Wood , Phone: 608-270-0940, E-mail: david@grrn.org Read the proposed rule and additional information about the rule. You can send this letter via email to the EPA directly or you can write your own letter and mail to the address in the letter. (For Windows Users: To send this letter select the letter with either a right mouse click or a select all, then click the right mouse button again to select copy. Next, click on the 'the EPA directly' which will bring up your mail program. Then right-click paste for to put your message in the text screen. Mac users: Use the Apple-command key) The rule is flawed! RCRA Docket Information Center Office of Solid Waste (5305G) USEPA Ariel Rios Building 1200 Pennsylvania Ave, NW Washington DC 20460 RE: Docket #F-2002-CRTP-FFFFF Proposed Rule; Cathode Ray Tubes (CRTs) and Mercury Containing Equipment Madam/Sir: Please accept the following comments to the US EPA's proposed rule for recycling of used cathode ray tubes (CRTs). The proposal streamlines some regulations with the intent of fostering re-use and recycling of CRTS. However, disturbingly the proposed rule ignores some of the most egregious problems and loopholes that allow very environmentally damaging CRT disposal. These include the dumping of CRTs made possible by regulatory exclusion for small quantity generators such as individuals. This equates to a massive amount of hazardous e-waste that can legally be dumped into our nation's soil. Even more shocking perhaps is the fact that the administration has ignored the frightening loophole that allows easy export of about 80% of e-waste that is collected for recycling, without control to Asia where it is known to be dumped and recycled in very hazardous conditions. Further, the proposal ignores the hazards inherent in circuit boards which are far more dangerous than CRTS as well as right-to-know provisions for communities. Specifically, the proposed rule should be amended in the following ways: · Full Landfill/Incinerator Ban: It is vital to once and for all, ban, nationwide all solid waste disposal of CRTs, circuit boards and any other wastes exhibiting hazardous characteristics. CRTs and circuit boards all fail the toxic leachate tests in landfill situations, and hazardous waste incinerators only serve to move pollutants to ash or air emissions. Loopholes of this kind not only fail to address a massive source of contamination, but moreover encourage circumvention avenues for larger generators while failing to promote individual awareness and responsibility of hazardous products among consumers. · Ban on Exports to Developing Countries: Market dynamics, the absence of controls or a prohibition against export of hazardous waste that almost all other countries possess, and the absence of a domestic electronics recycling infrastructure, already results in vast amounts of discarded products being exported for processing under horrific conditions with few human health or environmental safeguards. EPA was well aware of this situation when they published their proposed rule. They are also well aware that this export violates the agreed principles of environmental justice. Asian peoples are now asked to accept pollution that we have created simply because they are poorer. Yet the practical effect of the proposed rule in the absence of an export ban, will be to drive even more US e-waste to Asia. The proposed rule should prohibit export to non-OECD countries of non-working CRTs and CRT glass waste for any reason, consistent with the Basel Convention's 1995 Decision. · Responsible Recycling: It is not sufficient to simply encourage greater recycling of used CRTs. CRT recycling - and the recycling of all consumer electronics - pose threats to workers, communities and the environment if such recycling is not conducted under stringent performance standards, including environmental management systems to ensure best practices, tracking of wastes downstream to verify compliance with all applicable laws and show ultimate disposition of hazardous wastes, and worker health and safety protections. · Community Notice: The proposed rule removes the Common Sense Initiative (CSI) Council's recommendation that CRT recyclers and glass processors implement procedures for advising local communities of their activities and the potential for resident and worker exposure to lead and other materials. The EPA's proposed rule defers to a history or preference for "local authority" to provide notice, despite ample evidence of federal regulations providing community and worker right-to-know. These notice provisions must be included in the proposed rule. · Circuit Boards Must be Considered Hazardous: Despite claimed ignorance to the contrary, it is well known that circuit boards are even more hazardous than CRTs, particularly in landfill situations. The Australian government has made this data (www.ea.gov.au/industry/hwa/papers/scrap.html) available for some time. It is imperative that rules preventing landfill and export of circuit boards be instituted at once. Sincerely, Background For additional background on this issue: Exporting Harm: The High-Tech Trashing of Asia Poison PC/Toxic TV Sign the Electronics Take It Back Platform 2001 Report Card 2000 Report Card 1999 Report Card

Silicon Valley Toxics Coalition 760 N. First Street San Jose, CA 95112 Phone: +1 408-287-6707
Fax: +1 408-287-6771 e-mail: svtc@svtc.org
PRIVACY POLICY

The rule is flawed!

Background